Durable and returnable packing excluded from assessable value where cartons were reused and returned for further use.

Corrugated cardboard cartons used to pack excisable goods were treated as durable and returnable packing because they were reused more than once and were returned by customers for further use. On that basis, the packing fell within the statutory exception to inclusion of packing cost in assessable value under Section 4(4)(a)(i) of the Central Excise Act, 1944. The cost of such cartons was therefore not includible in assessable value.

---

---

Issues: Whether the cost of corrugated cardboard cartons used for packing excisable goods was includible in the assessable value, or whether the cartons were durable and returnable so as to fall outside the packing-cost component.

Analysis: The cartons were reused more than once and were returned by customers to the assessee, showing that they were capable of repeated use and were in fact returned for reuse. On that footing, they could not be treated as non-durable packing. Under Section 4(4)(a)(i) of the Central Excise Act, 1944, the cost of packing is includible in assessable value except where the packing is durable and returnable in nature.

Conclusion: The packing fell within the durable and returnable exception and its cost was not includible in the assessable value, in favour of the assessee.

---